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France - Syria Tax Treaty (as amended by 2004 exchange of notes) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 25

Members of Diplomatic Missions and Consular Posts

(1) No provision of this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special conventions.

(2) The provisions of Article 4 notwithstanding, any individual who is a member of a diplomatic mission, a consular post or a permanent delegation of a Contracting State situated in the other Contracting State or in a third-party State shall be considered, for the purposes of this Convention, a resident of the accrediting State provided that such person is subject, in the accrediting State, to the same duties in tax matters, in respect of his or her entire income, as residents of such State.

(3) This Convention shall not apply to international organizations, their officers or representatives, nor to persons who are members of a diplomatic mission, a consular post or a permanent delegation of a third-party State, provided that they are present on the territory of a Contracting State and are not subject in a Contracting State to the same duties in tax matters, in respect of their entire income, as residents of such State.